BREAKING: Leaked Draft Executive Order Suspending Conflict Minerals Law

Yesterday, several news outlets reported on what was claimed to be a leaked draft Executive Order that would, if signed by President Trump, suspend Dodd-Frank Section 1502 for a two year period by claiming it is in the US national security interest to eliminate US corporate due diligence activities concerning tin, tantalum, tungsten and gold (3TG).  The document offers no explanation as to  the reasoning behind the conclusion that national security interests are either currently threatened or how national security would improve by the action.  Further, the Executive Order cites incorrect and outdated information about the costs of the Rule.  In the end, none of that may matter as President Trump will almost certainly sign such an Order regardless.

Would that mean all conflict minerals traceability and reporting processes would immediately come to a halt?


First, there will continue to be customer demands for the information regardless of the SEC disclosure requirement, and you will have to meet your customer information requests or possibly jeopardize the business relationship. Second, the Order will very likely be challenged in court as was the President’s recent travel “ban” Executive Order.  Once it goes to court, who knows what will happen and how fast or slow.

We recommend continuing to move forward on the due diligence and reporting activities already underway for calendar year 2016.  But stay tuned – the situation is changing more rapidly and drastically than anyone had imagined.


2 thoughts on “BREAKING: Leaked Draft Executive Order Suspending Conflict Minerals Law”

  1. On his intension to issue 3TG executive order,President Donald Trump sees beyond what most sceptics would want others to believe. President Trump is proactive and wise.

    While american smelters,processors,refineries and manufacturers have been adhering to D-F1502 regulations,the other competitive world powers have been breaking the doors of tin,tantalum and tungsten exporters to fuel their stocks of advanced hightech consumer gadgets and military cutting edge advancements.

    The document does’nt have to explain the merits of such a decision either so that should be answered by any body,even with basic common sense.

    The rest of the world is ignoring that “conflict minerals” mindset and progressing ahead at the expense of America. Being at the privileged location along the supply chain,I can confirm emphatically that conflict tag is being overlooked always.

    So agonising to retain or repeal a self sabotaging law may not augur well with that “Make America great again” clarion call.

  2. I wonder whether companies who are using 3TGs care enough about their public image would continue to want to certify their products regardless of what happens?

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